The Associate General Counsel for Sanctions and AML Investigations, APAC, will report into the Financial Crimes Investigations Legal team in the Citigroup Legal Department. The attorney occupying this position will be responsible for working on a wide range of sanctions, AML (Anti Money Laundering), and ABC (Anti-Bribery and Corruption) legal issues across all product areas within the institution. The role will require close coordination with Citi's internal compliance, Sanctions, AML, and investigation functions on a regional and global level, reviewing and advising on, among other things, potential exposure for Citi as a result of financial crime concerns or allegations involving Citi clients, and, as relevant, providing assistance in interaction with regulators. The Associate General Counsel will be responsible for providing advisory support on transactional matters, handling law enforcement and regulatory inquiries, and conducting internal investigations related to potential violations of criminal and civil sanctions, AML, and ABC laws. Key Responsibilities:
Knowledge/Experience/ Technical skills
- The role will include responsibilities for sanctions, AML, and ABC matters.
- Supporting the Sanctions compliance teams on complex questions relating to compliance with OFAC, UK, and EU sanctions, and other relevant sanctions programs, working closing with other internal legal teams.
- Supporting the AML Compliance team in relation to ad hoc legal inquiries, including AML deal approvals, issues arising under the relevant Money Laundering legislation, suspicious activity reporting and reviewing AML language in agreements.
- Interacting directly with impacted businesses and external counsel, often within urgent timeframes.
- Working alongside compliance teams and regional management in dealing with responses to regulatory inquiries, legal production orders and submissions to sanctions authorities within the APAC region.
- Providing ad hoc support to internal investigations teams and the Ethics Office with regard to internal investigations related to AML, ABC and sanctions matters. Investigations may be initiated as a result of a law enforcement inquiry; one of the Bank's internal financial, fraud, or corporate security investigators; a Congressional inquiry; a matter brought to the General Counsel's Office attention by a Compliance or AML Compliance officer as a result of a suspected violation Bank Secrecy Act/Anti-Money Laundering statute or regulation, a referral from a senior manager in one of the Bank's businesses, or from a referral from the Bank's Ethics Office.
- Assisting with review of ABC compliance related questions, in particular in relation to the Foreign Corrupt Practices Act.
- The Associate General Counsel for Sanctions and AML Investigations must be able to analyze financial and other records; apply applicable laws and regulations to the specific inquiry or matter;
- Draft necessary memoranda, summaries or other written summaries and reports; and communicate orally and in writing, in a clear and concise manner.
- The ideal candidate for this position would have knowledge of US and APAC-related sanctions laws and regulations, APAC AML laws and regulations, and USA PATRIOT ACT requirements, and experience in drafting and filing certain regulatory filings such as suspicious activity reports.
Job Family Group:
- Law degree is required
- 10 to 14 years of overall experience since law school graduation, with substantial sanctions experience and experience in overseeing and conducting AML and ABC investigations.
- Experience working in a large financial institution or multinational company is preferred.
- Excellent communication skills, with proficiency in other APAC-related languages a plus.
- Experience with internal investigations, government contracting, data security, Economic Sanctions, FCPA.
Legal Job Family:
General Legal Time Type:
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